|Posted on Wednesday, October 21, 2020
Beginning in January 2021, home health agencies will be required to submit RAPs within five business days, or they will incur financial penalties. Furthermore, agencies will not receive any payment upon RAP submission. The purpose of the RAP will be changing to simply establish the HH period of care.
There has been a lot of confusion on the requirements needed for a no pay RAP submission. With this article, Corridor would like to provide our clients, partners and the home health industry with additional insights and recommended next steps to properly prepare for this upcoming change.
The MLN Matters (p. 2) published on September 24th, outlines the two requirements for a RAP to be submitted in CY 2021. This is very different (and much easier) than the current guidelines. The most significant change is that the plan of care (POC) does not have to be completed and submitted to the provider prior to the RAP to be submitted to the MAC.
The two requirements needed prior to a RAP submission are:
- The initial physician’s written or verbal order documented (does not have to be signed until final submitted)
- The initial visit within the 60-day certification period has been made and the patient has been admitted to HH care
So, as soon as the patient is admitted, the RAP can be submitted.
All other current requirements for the RAP submission will be now be separated from the RAP requirement in 2021; this includes coding review, OASIS submission, and completion of the Plan of Care. These revised requirements allow all the disciplines’ clinical documentation within the first 5-day window to be completed and considered to ensure your organization receives proper reimbursement on the final claim.
Additional clarification is still needed in some areas. For example, does the first visit in a recert period need to be completed before the RAP for that episode is submitted?
Corridor has been working with the National Association for Home Care and Hospice (NAHC) and the Homecare Technology Associates of America Committee (HCTAA) to ensure all aspects of these changes have been considered and the impact to our industry has been determined.
Many industry EMR providers have already begun implementing the workflow changes required to separate the RAP submission workflow from the POC and OASIS review/submission process. Agencies are encouraged to reach out to their EMR provider to determine how the workflow may be changing in 2021 for the RAP submission requirement. Agencies should also review current back office processes to determine the potential modifications needed in order to ensure the RAP is submitted within the required 5 day window.
CMS Transmittal 10254 published July 31, 2020
CMS Transmittal 10369 published September 24, 2020
MLN MM11855 published September 24, 2020
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